State v. Hatton’s Empirical Analysis
1977
Citation profile
107 state decisions
How this case has been cited
Cited by 109 later decisions — most recently April 2019 · most notably State v. Arnett (1978), State v. Celaya (1983)
107 state decisions — followed in 15 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Miranda v. State of Arizona Vignera · Oregon v. Mathiason · Michigan v. Mosley · Starnes v. Penrod Drilling Co. · United States v. Di Re
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 109 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Ajppellant assumes that the scope of the agents’ official duties is co-extensive with their power to arrest. But this is not so____ “Engaged in * * * performance of official duties” is simply acting within the scope of what the agent is employed to do. The test is whether the agent is acting within that compass or is engaging in a personal frolic of his own. It cannot be said that an agent who has made an arrest loses his official capacity if the arrest is subsequently adjudged to be unlawful.”
2 later decisions quote this exact passage · from the majority““The law of arrest by peace officers illustrates the discrepancy between law in the books and the law in action. The former not only antedates the modem police department, but was developed largely during a period when most arrests were made by private citizens, when bail for felonies was usually unattainable, and when years might pass before the royal judges arrived for jail delivery. Further, conditions in the English jails were then such that a prisoner had an excellent chance of dying of disease before trial.... [[Image here]] ... The rule developed when long imprisonment, often without the opportunity of bail, ‘goal [sic] fever,' physical torture, and other great dangers were to be apprehended from arrest, whether legal or illegal.... When the law of arrest developed, resistance to an arrest by a peace officer did not involve the serious dangers it does today. Constables and watchmen were armed only with staves and swords, and the person to be apprehended might successfully hold them off with his own weapon and thus escape.” Warner, The Uniform Arrest Act, 28 Va.L.Rev. 315, 315, 330 (1942).”
1 later decision quote this exact passage · from the majority““One who suffers the imposition of an unlawful police search has the assurance that any evidence so acquired is rendered inadmissible in a subsequent criminal trial by the exclusionary rule. Likewise any incriminating evidence obtained by exploiting an illegal arrest will be excluded in a subsequent criminal trial, [citation omitted]. And in any event damage remedies are available in the federal courts for violations of constitutional rights stemming from either an unlawful search or arrest.” United States ex rel. Kilheffer v. Plowfield, 409 F.Supp. 677, 680-81 (E.D.Pa.1976).”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.